Business Continuity and Disaster Recovery Plan

Conti Capital Investments, Inc.

April 1, 2008

In the event of an emergency or significant business disruption, Conti Capital Investments has designed the following procedures.  These procedures will be periodically reviewed and updated as need.  A copy of this plan will be maintained at the back up facility and with any other key members including PFGBEST.com (“PFGBEST”), the firm’s guarantor FCM.  All reviews will be documented in Schedule A.  Conti Capital Investments’ back up facility is in located at 265 Atwells Avenue, #6 Providence, RI 02903 Tel 401.743.0255.

Back-Up Facilities

Conti Capital Investments’ disaster recovery location will maintain the necessary equipment to continue business operations.   The following will be maintained at this offsite location.

• Copies of account files (stored electronically)
• Computer and other equipment used for order taking.
• Company telephones will be forwarded to this location.

All customer account information is also backed up at PFGBEST’s main office.  All employees will be contacted as soon as reasonably possible to discuss relocation to the back up facility.  Contact numbers for key employees follow.

Communications with Customers

In the event of a disaster, Conti Capital Investments will inform is clients that it cannot access its physical office.  This will be done via telephone and email.

Communications with PFG Personnel

Conti Capital Investments will immediately inform PFGBEST of any business disruption.  At such time, arrangements will be made with PFGBEST of any assistance that is needed with regards to customer communication and trading.

Third Party Disruptions

Conti Capital Investments has considered the impact on its business of disruptions encountered by third parties.  One of the most critical situations for Conti Capital Investments would involve a business disruption at PFGBEST.  If this happened, Conti Capital Investments would work with PFGBEST to ensure that business could continue with a firm that is an NFA member firm has a Plan which is compliant with NFA Compliance Rule 2-38.  As PFGBEST maintains multiple relationships, the potential disruption may be greatly minimized.

EMERGENCY CONTACTS

Schedule A

Business Continuity & Disaster Recovery Review Log